Station Compliance›Field Notes

There is a genre of broadcast compliance calendar that lists a dozen dates with confident precision, and it is misleading in a specific way: several of the dates it prints are not fixed. The Commission sets them each year by Public Notice, moves them, or waives the obligation entirely — and a calendar printed in January is stale by autumn.

So this one is organised by how reliable the date is, which is the thing that actually matters when you are deciding what to write in a calendar.

Genuinely fixed, every year

Quarterly issues/programs lists. Four dates, set by rule at § 73.3526(e)(12), and they do not move:

These are the ones to put in a calendar with confidence, and they are also the most enforced items in the file. The full article on quarterly lists covers what a compliant one contains.

The political file — continuous, not periodic. Under § 73.1943, records of requests for broadcast time go into the public file immediately. There is no deadline to diarise because the obligation is same-day. During an election season this is the item most likely to slip at an otherwise diligent station, because the pace is set by ad traffic.

Announced each year — check, do not assume

ETRS Form One. Every EAS Participant files it annually, but the deadline is set by Public Notice and it moves substantially. It was February 28 in 2023 and October 3 in 2025, and in at least one year it was extended after the fact. There is no permanent date to write down.

What to do instead: set your own annual reminder to check whether the window has been announced, rather than a reminder to file on a date you believe is fixed. Trade associations and state broadcaster groups reliably circulate it.

Note also that a nationwide EAS test does not happen every year — FEMA did not conduct one in 2025 — and Form One is due regardless of whether a test is scheduled.

Currently waived — do not diarise from an old list

Biennial ownership reports, FCC Forms 323 and 323-E. The long-standing rule at § 73.3615 puts these on a two-year cycle with a December 1 deadline in odd-numbered years, and most compliance calendars still print that.

The Media Bureau waived the filing requirement for 18 months. The next filing is set for June 1, 2027, or until further notice, whichever comes first.

This is the clearest example of why a printed calendar goes stale. A station working from a 2024 list would have spent last autumn preparing a filing that was not due.

Depends on your station

Licence renewal. Radio licences run eight years, and renewal deadlines are staggered by state — your filing date has nothing to do with the calendar year and everything to do with where your transmitter is. Look yours up once, then put it in a calendar with a year of lead time, because the public file audit you want to do before renewal takes longer than the application does.

EEO Annual Public File Report. Required for employment units with five or more full-time employees, on the anniversary date tied to your station's renewal cycle rather than a common national date. Units under five full-time employees are exempt. The EEO audit article covers what the report contains and what an audit asks for.

EEO audits. Roughly five percent of stations are selected at random each year, with about two months to respond. There is nothing to diarise; there is only being able to answer. The 2026 audit selected 400 stations, with responses due October 20, 2026.

One-time, and imminent

§ 11.35(d) — program chain security. September 29, 2026.

This one is genuinely a deadline rather than a recurring filing, and it is close. Every EAS Participant must have changed default passwords to strong ones, installed available security patches, and put a firewall or comparable network segmentation in front of remotely managed equipment that touches programming.

There is nothing to file — no certification, no report, no new recordkeeping. The obligation is to have done the work. The rule reference covers all three requirements, and the small-station question covers who it applies to, which is everyone.

The ongoing part is easy to miss: after September 29 the obligation does not end. Patches keep being issued, passwords still have to change when there is reason to believe they are compromised, and staff still turn over.

The one calendar entry that matters most

If you only add one recurring item, make it this: a quarterly half-hour to look at the file and the rack.

Put it on the same four dates as the quarterly lists, since you are in there anyway. Thirty minutes, four times a year:

1. Upload the quarterly issues/programs list, and confirm it is visible in the public file.
2. Scan the file for anything obviously missing from the last quarter.
3. Check whether any program chain equipment has a firmware update waiting.
4. Confirm nobody added a port-forwarding rule since last time.

Nearly every compliance failure described on this site — the missed quarterly list, the two-year EEO gap, the STL box still on its factory password — comes from the same root cause. Not negligence. An obligation that produces no daily symptom, at a station running with fewer people than the rules assume.

A recurring half-hour is a worse solution than a dedicated compliance person and a much better one than intention.